Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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The Appellate Authority cannot entertain a GST appeal filed beyond four months from communication of the adjudicating order, and Article 226 interference to bypass that statutory bar is confined to exceptional and extraordinary cases. Here, the order was served through the GST Portal and was within the taxpayer's knowledge, while the medical evidence did not show any disabling circumstance sufficient to explain the delay. The Court therefore found no exceptional ground to condone the delay or invoke writ jurisdiction, and the rejection of the appeal as time-barred was sustained.
The Appellate Authority cannot entertain a GST appeal filed beyond four months from communication of the adjudicating order, and Article 226 interference to bypass that statutory bar is confined to exceptional and extraordinary cases. Here, the order was served through the GST Portal and was within the taxpayer's knowledge, while the medical evidence did not show any disabling circumstance sufficient to explain the delay. The Court therefore found no exceptional ground to condone the delay or invoke writ jurisdiction, and the rejection of the appeal as time-barred was sustained.
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